To comply with the Data Protection Act 1998, Fidelity Works Ltd is registered with the Information Commissioners Office (ICO) with registration number Z3523198
Throughout this Policy “Us”, “We” and “Our” means Fidelity Works Ltd and “You” and “Your” means the user of the website or any other service offered by Fidelity Works Ltd.
This Policy, along with our “Website Terms & Conditions” forms part of the agreement you make when you use our services. If you do not agree with any part of this Policy or the Website Terms and Conditions please do not continue to use this site.
The information we may collect about you
We may collect, store and process the following about you:
Information provided by you when completing the online application, or subsequently given to us verbally or in writing. This information may include, but is not limited to your personal details, contact details, employment details and financial details (including those of your bank and debit card).
Information passed to us from other lenders, lead generators or credit brokers. This may include some or all of the information described above.
Information obtained about you from third parties such as Credit Reference Agencies (CRAs) and Fraud Prevention Agencies (FPAs).
Details of all transactions we carry out during our relationship in respect of your application and/or loan.
Correspondence sent to or received by us from you or other third parties in relation to you, your application or your loan, including system notes made following such communications (please note that calls may be recorded and/or monitored for our protection and yours).
Details given by you if we invite you to take part in a survey (of course you will not be obliged to take part).
Details of when you have visited our website and what you have done while there.
Anything else that we can justifiably and legally collect as part of our dealings with you.
Call recordings & call monitoring
We may record or monitor calls made to or received from you which we do for your protection and ours. We will do this for the following purposes:
To conduct routine monitoring and assessment of the way our staff handled the call to ensure it is compliant with both the regulations and our own procedures and that the service provided meets the high quality we expect.
To provide a record of your explicit consent where this is required by us to perform an action where that consent is not required to be in writing.
To provide a record of information which you have provided during our dealings with you which we have based a decision or action upon.
Storing and transmitting your information
When you entrust us with your data we will aim to protect it as if it were our own. All data is stored on our secure servers where access is restricted to people and organisations that we have carefully assessed and deem suitable. For extra security, some of the data is also encrypted. Information may be transferred to third parties which may be located outside the European Economic Area. We will ensure that your personal information is protected to the level of standards in accordance with the Data Protection Act 1998.
Use of your information
To assess your application for credit (including using data from third parties to confirm your identity and assess your creditworthiness), manage your account, collect payments and pursue debts owed to us.
To assess any subsequent applications for credit.
To keep you up to date with changes to your account and advise you of offers or promotions that we feel may be of interest to you.
To undertake statistical analysis to help us improve our underwriting or collection strategies, including using appointed third parties to undertake such analysis on our behalf.
To make additional data requests to 3rd parties to keep our information up to date and to be able to offer you new products or services.
Disclosure of your information
There will be times when we either want to, need to or have to by law pass your information to others. These circumstances include, but are not limited to:
When we employ a third party to assist us in processing your application or administer your account.
When we employ a third party to assist us in recovering monies owed under your agreement when you have failed to make payment.
If we transfer or sell your debt.
If we employ a third party to undertake statistical analysis of our data for the purpose of improving our strategies and processes.
If we use a third party to prepare or send communications on our behalf.
When we are obliged by law to provide information about you and your dealings with us, or when we need to do so in order to enforce any agreement we have with you or protect our rights and/or assets.
If we sell or transfer all or some of Fidelity Works Ltd assets to another legal entity we may transfer your information to them.
Anyone we employ as an Agent to act on our behalf.
Credit Reference Agencies (CRAs) and Fraud Prevention Agencies (FPAs) (See the section “Use of Credit Reference Agencies and Fraud Prevention Agencies”)
For marketing purposed as detailed in the section of this policy “Use of your information for marketing purposes”.
Access to the information we hold on you
Under the Data Protection Act you have the right to ask us to provide any or all of the information we hold about you, known as a Subject Access Request (SAR) To make a SAR please email email@example.com. We have up to 40 days to provide you with this information and may make a charge of up to £10 for doing so. Please therefore enclose a cheque for £10 payable to ‘Fidelity Works Ltd’ with your request which we will return to you if we decide not to charge on this occasion. If you are unable to pay by cheque please contact us for details on other payment methods available. The 40 days will not begin until we have received payment.
Use of your information for marketing purposes
By starting the application you agree to us contacting you with marketing material about related products and services that we offer. Furthermore you agree that we may contact you with details of related products and services offered by carefully selected third parties that we feel may be of interest to you. Furthermore you expressly invite us to contact you about such services that may require such invitation.
You may Opt-Out of either of these communications by sending an email to firstname.lastname@example.org with “OPT-OUT” as the subject and details of the marketing you wish to opt out of in the body of the email, or by writing to us at 1 Forbes Business Centre, Kempson Way, Bury St Edmunds, IP32 7AR.
By completing the application form you also agree to us sending you information about products and services that either we offer or those from third parties which may, or may not, be directly related to short term consumer finance but which we think may be of interest. You also agree that we may pass your details to such third parties who may contact you directly. You can opt out of this as described above
We will honour your opt-out request once we have had reasonable opportunity to process it, however if we have already passed you details to other third parties you will need to contact them directly to unsubscribe or opt-out.
In all of the above you agree to the following methods of contact:
Use of your information when you opt to use our optional brokerage service
In order to provide you with this service we will be required to pass certain items of your personal and non-personal data to the single credit broker we work with. They in turn will pass your details to other organisations to enable them to decide whether they feel that they can assist you. If you tick the ‘opt in’ box in the application you give your consent to this.
We will never pass on your Debit Card Number.
The organisations that are asked to consider your application may search the files of one or more Credit Reference Agency or Fraud Prevention Agency in order to determine whether they can help you. Below is a guide to Credit Reference Agencies and Fraud Prevention Agencies which describes who they are and what they do. You will be consenting to this if you choose to use this service.
The organisation who accepts your application and invites you to continue with it on their website may send you marketing communications either in relation to that application or from time to time about other products and services that they feel may be of interest to you. Once your details have been passed to them you would need to contact them directly to ‘Opt Out’ of further marketing communications as we will not be able to do this on your behalf. Details of how to do this can be found on their website or in any marketing communication they send to you.
If, in addition, you also want to opt out of further marketing from us, this should be done in one of the ways detailed in the previous section.
Cookies and how we use them
A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps web applications to respond to you as an individual by gathering and remembering information about your preferences and which pages you visit. A cookie in no way gives us access to your computer or any information about you, other than the information you choose to share with us.
In addition to using cookies, we might also use web tools to collect information about your browsing activities whilst on our website. In this respect the information that is provided is similar to the information supplied by cookies, and we use it for the same purpose.
Any information that we acquire about you using cookies or web tools is subject to the same restrictions and conditions as any other information we collect about you.
Use of Credit Reference Agencies and Fraud Prevention Agencies
As part of our lending decision we may search the records of one or more Credit Reference Agencies or Fraud Prevention Agencies. This will be for the purposes of credit assessment, identity confirmation, validation of your debit card and bank account, the prevention of money laundering and account management. We will also pass information about you and your agreement to such agencies, including reporting missed payments and ultimately registering a default on your credit file if you fail to repay your loan. A full guide to such agencies can be found below
We may also from time to time make further searches of CRA files to keep your account up to date and assist with any subsequent lending decision or to manage your account.
A Guide to the use of your personal data by Fidelity Works Ltd
and Credit Reference and Fraud Prevention Agencies
Q: What is a credit reference agency?
A: Credit reference agencies (CRAs) collect and maintain information on consumers' and businesses' credit behaviour, on behalf of organisations in the UK.
Q: What is a fraud prevention agency?
A: Fraud Prevention Agencies (FPAs) collect, maintain and share, information on known and suspected fraudulent activity. Some CRAs also act as FPAs.
Q: Why do you use them when I have applied to your organisation?
A: Although you have applied to us [organisation name] and we will check our own records, we will also contact CRAs to get information on your credit behaviour with other organisations. This will help us make the best possible assessment of your overall situation before we make a decision.
Q: Where do they get the information?
A: From publicly available information: -
The Electoral Register from Local Authorities
County Court Judgments from Registry Trust.
Bankruptcy (and other similar orders) from the Insolvency Service.
Fraud information may also come from fraud prevention agencies.
Credit information comes from information on applications to banks, building societies, credit card companies etc and also from the conduct of those accounts.
Q: How will I know if my information is to be sent to a CRA or FPA?
A: You will be told when you apply for an account if your application data is to be supplied. The next section of this leaflet will tell you how, when and why we will search at CRAs and FPAs and what we will do with the information we obtain from them. We will also tell you if we plan to send payment history information on you or your business, if you have one, to CRAs. You can ask at any time the name of CRAs and FPAs.
Q: Why is my data used in this way?
A: We and other organisations want to make the best possible decisions we can, in order to make sure that you, or your business, will be able to repay us. Some organisations may also use the information to check your identity. In this way we can ensure that we all make responsible decisions. At the same time we also want to make decisions quickly and easily and, by using up to date information, provided electronically, we are able to make the most reliable and fair decisions possible.
Q: Who controls what such agencies are allowed to do with my data?
A: All organisations that collect and process personal data are regulated by the Data Protection Act 1998, overseen by the Information Commissioner's Office. All credit reference agencies are in regular dialogue with the Commissioner. Use of the Electoral Register is controlled under the Representation of the People Act 2000.
Q: Can just anyone look at my data held at credit reference agencies?
A: No, access to your information is very strictly controlled and only those that are entitled to do so, may see it. Usually that will only be with your agreement or (very occasionally) if there is a legal requirement.
Please read this section very carefully, it will vary from lender to lender
What we do
1. When you apply to us to open an account, this organisation will: -
a. Check our own records for information on: -
i. Your personal accounts;
ii. and, if you have one, your financial associates1 personal accounts;
iii. if you are an owner, director or partner in a small business2 we may also check on your business accounts.
b. Search at credit reference agencies for information on: -
i. Your personal accounts: -
ii. and, if you are making a joint application now or have ever done the following we will check your financial associates' personal accounts as well: - previously made joint applications; or have joint account(s); or are financially linked3
ii. if you are a director or partner in a small business we may also check on your business accounts;
c. Search at fraud prevention agencies for information on you and any addresses at which you have lived and on your business (if you have one)
2. What we do with the information you supply to us as part of the application: -
a. Information that is supplied to us will be sent to the credit reference agencies.
b. If you are making a joint application or tell us that you have a spouse or financial associate, we will: -
i. Search, link and/or record information at credit reference agencies about you both.
ii. Link any individual identified as your financial associate, in our own records
iii. Take both your and their information into account in future applications by either or both of you.
iv. Continue this linking until the account closes, or is changed to a sole account and one of you notifies us that you are no longer linked.
So you must be sure that you have their agreement to disclose information about them.
c. If you give us false or inaccurate information and we suspect or identify fraud we will record this and may also pass this information to fraud prevention agencies and other organisations involved in crime and fraud prevention.
d. Your data may also be used by us to offer you other products, but only if you have given your permission. That will be on the front of any form that you have completed.
3. With the information that we obtain we will: -
a. Assess this application for credit and/or;
b. Check details on applications for credit and credit related or other facilities
c. Verify your identity and the identity of your spouse, partner or other directors/partners and/or;
d. Undertake checks for the prevention and detection of crime, fraud and/or money laundering.
e. We may use scoring methods to assess this application and to verify your identity.
f. Manage your personal and/or business account (if you have one) with ourselves.
g. Undertake periodic statistical analysis or testing to ensure the accuracy of existing and future products and services.
h. Any or all of these processes may be automated.
4. What we do when you have an account: -
a. Where you borrow or may borrow from us, we will give details of your personal and/or business account (if you have one), including names and parties to the account and how you manage it/them to credit reference agencies.
b. If you borrow and do not repay in full and on time, we will tell credit reference agencies.
c. We may make periodic searches of our own group records and at credit reference agencies to manage your account with us, including whether to make credit available or to continue or extend existing credit. We may also check at fraud prevention agencies to prevent or detect fraud.
d. If you have borrowed from us and do not make payments that you owe us, we will trace your whereabouts and recover debts.
What Credit Reference and Fraud Prevention Agencies do
5. When credit reference agencies receive a search from us they will:
a. Place a search 'footprint' on your credit file whether or not this application proceeds. If the search was for a credit application the record of that search (but not the name of the organisation that carried it out) may be seen by other organisations when you apply for credit in the future.
b. Link together the records of you and anyone that you have advised is your financial associate including previous and subsequent names of parties to the account. Links between financial associates will remain on your and their files until such time as you or your partner successfully files for a disassociation4 with the credit reference agencies.
6. Supply to us: -
a. Credit information such as previous applications and the conduct of the accounts in your name and of your associate(s) (if there is a link between you - see 1b above) and/or your business accounts (if you have one).
b. Public information such as County Court Judgments (CCJs) and bankruptcies.
c. Electoral Register information.
d. Fraud prevention information.
7. When information is supplied by us, to them, on your account(s): -
a. Credit reference agencies will record the details that are supplied on your personal and/or business account (if you have one) including any previous and subsequent names that have been used by the accountholders and how you/they manage it/them.
b. If you borrow and do not repay in full and on time, credit reference agencies will record the outstanding debt.
c. Records shared with credit reference agencies remain on file for 6 years after they are closed, whether settled by you or defaulted.
8. How your data will NOT be used by credit reference agencies: -
a. It will not be used to create a blacklist.
b. It will not be used by the credit reference agency to make a decision.
9. How your data WILL be used by credit reference agencies:
a. The information which we and other organisations provide to the credit reference agencies about you, your financial associates and your business (if you have one) may be supplied by credit reference agencies to other organisations and used by them to
i. Prevent crime, fraud and money laundering by, for example checking details provided on applications for credit and credit related or other facilities
ii. Check the operation of credit and credit-related accounts
iii. Verify your identity if you or your financial associate applies for other facilities.
iv. Make decisions on credit and credit related services about you, your partner, other members of your household or your business.
v. Manage your personal, your partner's and/or business (if you have one) credit or credit related account or other facilities.
vi. Trace your whereabouts and recover debts that you owe.
vii. Undertake statistical analysis and system testing.
10. How your data may be used by fraud prevention agencies:
The information which we provide to the fraud prevention agencies about you, your financial associates and your business (if you have one) may be supplied by fraud prevention agencies to other organisations and used by them and us to : -
a. Prevent crime, fraud and money laundering by, for example;
i. checking details provided on applications for credit and credit related or other facilities
ii. Managing credit and credit related accounts or facilities
iii. Cross Checking details provided on proposals and claims for all types of insurance.
iv. Checking details on applications for jobs or when checked as part of employment
b. Verify your identity if you or your financial associate applies for other facilities including all types of insurance proposals and claims.
c. Trace your whereabouts and recover debts that you owe.
d. Conduct other checks to prevent or detect fraud
e. Undertake statistical analysis and system testing.
11. Your data may also be used for other purposes for which you give your specific permission or, in very limited circumstances, when required by law or where permitted under the terms of the Data Protection Act 1998.
12. Your data may also be used to offer you other products, but only where permitted
How to find out more
You can contact the CRAs currently operating in the UK; the information they hold may not be the same so it is worth contacting them all. They will charge you a small statutory fee.
CallCredit, Consumer Services Team, PO Box 491, Leeds, LS3 1WZ or call 0870 0601414
Equifax Ltd, Customer Service Centre, PO Box 10036, Leicester, LE3 4FS or call 0800 014 2955 or 0333 321 4043 or log on to www.myequifax.co.uk
(Calls to 0800 numbers are free from UK landlines and since July 2015 free from UK mobiles, calls to 0333 numbers from landlines and mobiles are normally included in bundled call packages, otherwise calls cost 9.58p per minute and 15.97p connection fee from a BT landline. Other networks and mobiles may vary.)
Experian, Consumer Help Service, PO Box 8000, Nottingham NG80 7WF or call 0844 4818000 or log on towww.experian.co.uk
Perfect Data Solutions Limited t/a Lending Metrics), Lancaster Court, 8 Barnes Wallis Road, Fareham, Hampshire, PO15 5TU, United Kingdom
Perfect Data have asked us to provide you with the following information:
“Please read the following information very carefully:
As a responsible lender, Fidelity Works Ltd has a legal obligation to take steps to ensure that our customers are creditworthy.
We use a variety of methods to try to make sure that we do not lend money to people who are in financial difficulty. One of these is to carry out a credit reference check. In order to do this, we shall pass the personal data that you provide to us in your loan application to a credit reference agency (CRA) called Perfect Data Solutions Limited which trades as Lending Metrics. Lending Metrics provide us with data about a customer's credit history and borrowing habits. You can contact Lending Metrics at Lancaster Court, 8 Barnes Wallis Road, Fareham, Hampshire, PO15 5TU, United Kingdom in writing to request the information that they hold about you (please note, a small statutory fee may be payable).”
1 A financial associate will be someone with whom you have a personal relationship that creates a joint financial unit in a similar way to a married couple. You will have been living at the same address at the time. It is not intended to include temporary arrangements such as students or rented flat sharers or business relationships.
2 A small business is defined as an organisation which might be sole trader, partnership or a limited company that has three or less partners or directors.
3 Credit reference agencies may link together the records of people that are part of a financial unit. They may do this when people are known to be linked, such as being married or have jointly applied for credit or have joint accounts. They may also link people together if they, themselves, state that they are financially linked.
4 Financial associates (see 1 a) iii) may "break the link" between them if their circumstances change such that they are no longer a financial unit. They should apply for their credit file from a credit reference agency and file for a "disassociation".